Privacy Policy
Cordovan Capital Management Limited (“CCML”, “we”, “us”, “our”) is committed to protecting your personal data and respecting your privacy. This Privacy Policy explains how we collect, use and safeguard your personal data when you interact with us, including through our website, cordovancapital.com. We process personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
- 1. Data Controller
Cordovan Capital Management Limited
The Kelvin
17 College Square East
Belfast, BT1 6DE
United Kingdom
If you have any questions about this Privacy Policy or how we process your data, please contact us at the above address.
- 2. How We Collect Your Personal Data
We may collect personal data in the following ways:
Direct interactions: when you contact us, engage with us as a prospective, current or former client, or provide information to us in the course of our services.
Website interactions: when you visit our website, submit information through online forms, or allow cookies and analytics technologies to operate.
Business contact: when you provide a business card or exchange professional contact details with our staff.
- 3. Categories of Data We Collect
The personal data we may collect includes:
Your name
Your job title
Your employer’s name
Your professional / business contact details (telephone number, email address, office address)
In the normal course of business we do not collect special category data (e.g., health, ethnicity, or religion).
In exceptional circumstances, we may process details of any criminal convictions where you voluntarily disclose this to us in a business context, in accordance with Article 10 UK GDPR.
We do not knowingly collect personal financial data or other sensitive information via our website.
- 4. How We Use Your Personal Data (Legal Bases)
We may process your personal data for the following purposes:
a. To provide our services to you
Legal basis: performance of a contract or legitimate interest in operating and managing our business.
b. To respond to enquiries or requests for information
Legal basis: legitimate interest in responding to potential and existing clients.
c. To comply with legal or regulatory obligations
For example, responding to requests from regulatory bodies (such as the FCA), law enforcement, or government authorities.
Legal basis: legal obligation.
d. Website operation and security
We process basic technical information (e.g. IP addresses, browser type) to ensure the website functions correctly and securely.
Legal basis: legitimate interests in operating our website.
e. Analytics and website performance monitoring
We use Google Analytics to understand how visitors interact with our website and to improve its performance.
Legal basis: consent (obtained via our cookie banner).
- 5. Cookies and Tracking Technologies
Essential Cookies
Our website uses standard WordPress and server-level cookies necessary for site functionality. These operate on the basis of legitimate interests.
Analytics Cookies
We use Google Analytics to collect anonymised information about website usage, including:
- pages visited
- time spent on pages
- referring sites
- device/browser information
Analytics cookies are non-essential and only operate where you provide explicit consent via the cookie banner. You can withdraw your consent at any time by adjusting your cookie preferences in your browser or deleting cookies. For more details on cookies used by Google Analytics, visit: https://policies.google.com/technologies/cookies
- 6. Who We Share Your Personal Data With
We may share your personal data with the following categories of recipients:
- Service providers who support our business operations (e.g. IT hosting, website management, professional advisors).
- Microsoft 365, which we use for email and document management.
- Regulatory or governmental bodies where required by law.
- Legal advisers in connection with legal proceedings.
All service providers act under appropriate data processing agreements.
We do not sell, rent or trade your personal data.
- 7. International Transfers
CCML is based in the UK.
Some of our service providers, including Microsoft 365 and Google, may store or process personal data outside the UK.
Where this occurs, we ensure appropriate safeguards are in place, such as:
UK government adequacy decisions, or
Standard Contractual Clauses (SCCs) approved by the UK government.
These measures ensure your data remains protected to UK GDPR standards.
- 8. Data Retention
We retain personal data only for as long as is necessary for the purposes for which it was collected, or to comply with legal, regulatory, and professional obligations.
Typical retention periods include:
Client-related data: up to 7 years after the end of the client relationship.
Enquiry correspondence: up to 2 years after last contact.
Website analytics data: typically 14 months (Google Analytics standard retention) unless otherwise configured.
Where no retention period is prescribed, we retain data only for as long as necessary for legitimate business purposes.
- 9. Your Rights Under UK GDPR
You have the following rights in relation to your personal data:
Right of access – to request a copy of the data we hold about you.
Right to rectification – to correct inaccurate or incomplete data.
Right to erasure – to request deletion of your data in certain circumstances.
Right to restrict processing – to limit our use of your data.
Right to object – including an absolute right to object to processing for direct marketing (not applicable here).
Right to data portability – to receive your data in a machine-readable format.
Right to withdraw consent – e.g., for analytics cookies.
Right to lodge a complaint with the Information Commissioner’s Office (ICO):
https://ico.org.uk Tel: 0303 123 1113
- 10. Automated Decision-Making
We do not use your personal data for automated decision-making that has legal or significant effects.
Website analytics may involve basic automated profiling (e.g. aggregated visitor behaviour), but this does not identify individuals.
- 11. Updates to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or in applicable law. Any updates will be posted on this page with an updated revision date.